2024 Consolidated Non-Financial Information

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General Information. ESRS-2

0.1. Basis for presentation

0.1.1. BP-1: General basis for preparation of sustainability Statement of Non- Financial Information and Sustainability Report

The ACS Group has prepared this Statement of Non-Financial Information and Sustainability Report in accordance the requirements of the guide published by the Spanish Stock Market Commission (CNMV) on presentation of directors reports of listed entities, and the Spanish Non-Financial Information Reporting and Diversity Act 11/2018 [Ley sobre divulgación de información no financiera y diversidad]. It also followed Annex I (on European sustainability reporting standards, ESRS) of Commission Delegated Regulation (EU) 2023/2772 of 31 July 2023 supplementing Directive 2013/34/EU of the European Parliament and of the Council as regards sustainability reporting standards.

The report covers all of the ACS Group's activities in all the countries where it has a presence. The published information includes the operations carried out in Integrated Solutions, Engineering and Construction, Infrastructure Investment and Other Business business units by companies controlled by the ACS Group, which are detailed in the Group's consolidated annual financial statements.

This consolidated Sustainability Report covers all the information corresponding to the companies of the business areas mentioned in the previous point, exempting them from the obligation to file an individual report. It is important to note that the scope of the Sustainability Report is aligned with the Group's financial statements.

As part of the Double Materiality process, a value chain analysis has been carried out, covering both the Group's upstream and downstream operations and stakeholders, and its own operations. This approach has made it possible to define the scope of the Report, identify and confirm the stakeholders affected, and determine the actions and operations where the ACS Group has a direct and/or indirect influence.

The ACS Group partially reports information on its value chain, in accordance with the transitional provision on value chains included in the ESRS standards. The Group aims to continue its work on collecting information on its value chain.

It is important to note that no information related to intellectual property or innovation has been omitted. In addition, ACS has not taken the exemption from the obligation to disclose impending developments or matters in the course of negotiation, provided under Articles 19a(3) and 29a(3) of Directive 2013/34/EU.

In this report, the ACS Group has availed itself of the "List of phased-in disclosure requirements" transitional provision to postpone reporting certain disclosure requirements from that list.

0.1.2. BP-2: Disclosures in relation to specific circumstances

0.1.2.1. Time horizons

The ACS Group has aligned the definitions of its time horizons with the ESRS 1 standard.

• Short term: One year, coinciding with the ACS Group's financial year.
• Medium term: From the end of the ACS Group's financial year to five years later.
• Long term: Over five years.

Time horizons have been defined for all the topics addressed, with the exception of ESRS E1 - Climate Change, where they have been extended to longer time horizons. This exception is due to the fact that the

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time horizons proposed by the ESRS standard are considered insufficient to adequately address the particularities and challenges associated with climate change. In addition, we have sought to align the horizons with the Group's strategic targets and actions on climate change, which are designed to be implemented and achieved in the long term. These horizons are:

• Short term: Over five years.
• Medium term: Five to fifteen years.
• Long term: From fifteen years to 2045
  0.1.2.2. Value chain estimates

To report the quantitative and qualitative information related to the value chain, the criterion of obtaining information from direct sources has been followed. In the specific cases in which it has not been possible to obtain this information directly, the method for obtaining the data is explained in the corresponding sections. The Group is in the process of continuously improving its data quality and will continue to implement measures to improve the direct collection of this information in the coming years.

0.1.2.3. Sources of estimation and uncertainty of results

This report reports quantitative information that, in some cases, may be subject to a high degree of uncertainty due to its forward-looking nature, among other factors. In these cases, the calculation methodology will be reported, including the degree of uncertainty, the sources used, and the assumptions used to obtain the data.

In addition, in preparing this report, certain disclosure requirements under the applicable legislation have been interpreted that are not clearly defined and that may be interpreted differently.

0.1.2.4. Changes in the preparation or presentation of sustainability information

In the reporting years covered by this report, ACS Group took part in transformation processes that involved organisational and administrative changes, which resulted in a change in the scope of certain indicators.

It should be noted that on 23 April 2024, 10% of the shares in Thiess were repurchased, bringing it back into the ACS Group's scope of full consolidation, incorporating the non-financial data as of May 2024, and thus homogenising the reporting of non-financial and financial information in the current year.

As far as possible, the information included in this report has been organised in such a manner that stakeholders may interpret the changes undergone by the ACS Group with respect to previous years. Due to the change in the standard followed for this report (from GRI to ESRS), certain figures have been recalculated with the same scope as those reported in 2024 so that, whenever possible, they can be more comparable with other years. With regard to the variations resulting from restatements of the data, the differences are explained in the corresponding sections. In regard to indicators that indicate that "it was not possible to recalculate the figures retroactively for certain indicators", the historically reported data is included for the purposes of information.

It is important to note that the ACS Group is in the process of improving the processes for collecting data in line with the targets set in its Sustainability Master Plan, to improve their scope, quality and uniformity. These processes may lead, where possible, to restatement of the information from previous years to facilitate their comparability and correct interpretation.

In this regard, the following factors must be considered in the year-on-year comparisons of absolute data within the ACS Group:

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• Changes in its business activities and structure: the ACS Group has a high level of geographical and activity diversification, which implies that year-on-year changes in the business mix, the organic growth of the business itself, the acquisitions or divestment carried out or external factors may lead to substantial changes in the consumption or eco-efficiency indicators presented.
• Comparability of the activities and progress of the projects: the eco-efficiency indicators presented relate to the purchases or consumption carried out in the ACS Group projects, whether through its own projects or proportionally through projects in which it participates through temporary joint ventures (UTEs) or joint ventures. The nature of the projects carried out by the ACS Group is very variable and each type of project has a different impact on eco-efficiency indicators. In the large projects carried out by the Group, the phase in which the projects are located also represents significant differences in consumption.
• Improvement in data quality: given the size and operational decentralisation of the ACS Group, an improvement process is being carried out in the collection of data, in addition to a homogenisation of the processes and standards for their collection and reporting, which entails, where possible, restatement of previous years to show the same scope and methodology. This process is particularly significant in the indicators related to greenhouse gas emissions. The method for calculating the carbon footprint is in the process of continuous improvement and the ACS Group, in accordance with its 2025 Sustainability Master Plan, is improving the scope and quality of the data reported, especially in scope 3 emissions.

In 2024, following best market practices, the ACS Group, in its target of improving the completeness and coverage of the indicators, made its best estimate for the data from the Group's companies or projects for which it has not been possible to obtain real data. In these cases, this was indicated throughout the chapters. The ACS Group, in its target of constant improvement, will continue to work to achieve 100% coverage from direct sources.

0.1.2.5. Information on errors from prior periods

If a material error is identified in the information reported in previous years, that information will be corrected in this report in the relevant section, indicating the nature of the error, the correction if possible and, if not, the circumstances that gave rise to the error.

0.1.2.6. Information derived from other legislation or generally accepted pronouncements on sustainability reporting

This sustainability report includes information disclosed in accordance with Article 8 of Regulation (EU) 2020/852 of the European Parliament and of the Council, as well as information in accordance with the Delegated Regulations of the European Commission (EU Taxonomy) and the Spanish Non-Financial Information Reporting and Diversity Act 11/2018 [Ley sobre divulgación de información no financiera y diversidad]. In this regard, information is disclosed on the environmental targets defined in the Taxonomy Regulation.

This group report also serves as a progress report on the implementation of the UN Global Compact principles (www.unglobalcompact.org) and is published on the organisation's websites.

0.1.2.7. Incorporation by reference

The environmental provisions and guarantees of the ACS Group are detailed in Note 20. Provisions of the Consolidated Financial Statements of ACS.

The average number of employees of the ACS Group is detailed in Note 28.02. Personnel expenses of the Consolidated Financial Statements of ACS.

Events after the end of the financial year are referenced in Note 32 of the Consolidated Financial Statements.

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0.1.2.8. Events after the reporting date

Note 32 of the Consolidated Financial Statements of ACS details the events that took place after the end of the financial year.

These events do not significantly affect the material IROs' identified in the double materiality analysis performed for this report.

0.2. Strategy and business model

0.2.1. SBM-1: Strategy, business model and value chain

The ACS Group is a global infrastructure supplier made up of leading companies in developing, constructing and operating engineering, civil engineering and building projects and new-generation solutions in such sectors of the future as energy, digitalisation and smart mobility.

The Group's companies work in an integrated manner in the three most highly developed markets in the world (North America, Asia-Pacific and Europe), generating synergies and ensuring that ACS is present along the entire value chain of the infrastructure business. The main countries in which the ACS Group carried out its activity in 2024 are: The United States with 57.0% of sales, Australia with 21.2% of sales, Spain with 8.7% of sales, Canada with 3.9% of sales, Germany with 2.4% of sales and the United Kingdom with 1.2% of sales. The percentage of sales in the rest of the 28 countries in which the ACS Group carried out its activity in 2024 represents 5.7% of its total sales. At 31 December 2024, the ACS Group has a total of 157,284 employees, 53.4% of whom are located in Spain, 13.8% in the United States and 11.1% in Australia.

The activities carried out by the ACS Group are divided into the following business areas:

• Integrated solutions: through the companies Turner and CIMIC, the ACS Group designs, builds and operates integral projects with high added value. As at December 2024, Turner's sales amounted to EUR 19,264 million and Cimic's sales amounted to EUR 10,213 million.
• Civil engineering and construction: performance of traditional infrastructure projects, both in civil engineering and construction. In this market segment, the Group has Dragados, Hochtief and Flatiron Dragados with combined sales of EUR 9,505 million as at 31 December 2024.
• Infrastructure: the Group has a strong position as an operator of brownfield projects through Abertis, which is consolidated by the equity method, while it also invests in the development of greenfield assets through Iridium, Hochtief PPP Solutions and Pacific Partnerships. Sales in this business area amounted to EUR 173 million as at December 2024.
• Corporation and Other Businesses: mainly includes service activities (Clece), industrial assets, real estate activities (Cogesa), and the Group's own corporate expenses. The 2024 sales were EUR 2,478 million.

The ACS Group's business model aims to create shared value for all its stakeholders, focusing on its shareholders and investors, the people who make up the company, its customers, partners and suppliers, public administrations and regulatory authorities, and the communities in which ACS companies operate. This business model is described in chapter 2.4. of the Consolidated Directors' Report.

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The ACS Group's Value Chain

The ACS Group's Code of Conduct for Business Partners describes the chain of activities ("value chain") as the activities of the Business Partners involved in the upstream and downstream links in the production of goods or provision of services by ACS and its Group companies.

The ACS Group's Value Chain provides a comprehensive view of the Company, from the phase before its operations, to the execution of its work and its subsequent impact. Also referred to as the Chain of Activities in the Group's policies, it is composed of the following links:

Upstream

This phase includes all the activities and stakeholders whose participation is fundamental or who are directly involved in carrying out the ACS Group's operations and services. Among the most relevant elements are:

• Shareholders: The ACS Group's shareholders are investors who own stakes in the Company and provide the financial resources necessary for its growth and stability. By participating in the General Shareholders' Meeting and their influence on strategic decisions, they help define the Company's direction, including key aspects such as its business model, investments and commitment to sustainability.
• Suppliers: Suppliers are strategic partners of the ACS Group, providing it essential inputs and services for it to carry out its activities. They are classified into the following categories:
• • Materials suppliers: These suppliers supply raw materials and key products for carrying out the Group's projects.
  • Service providers:These suppliers offer support in areas such as logistics, transport and consultancy, among other essential services for the Group's operations.
  • Contractors:These suppliers represent a critical segment within the supply chain, as they carry out construction activities on ACS Group projects, playing a fundamental role in the delivery of infrastructures.

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• Regulators: Regulators play a key role in the Group's business, setting the regulatory framework to which its operations must conform. ACS requires strict compliance with current legislation and adapts to regulatory changes to operate in a responsible and sustainable manner.
• Funders: Funders are entities, such as banks and investment institutions, that provide the financial resources necessary for carrying out projects and operations. Their support enables the Group's financial viability and facilitates its growth in strategic markets. The confidence of these agents in the ACS Group's management directly influences its capacity to expand and carry out high-impact initiatives.
• ACS Group companies: In certain circumstances, companies in the Group enter into business relationships with each other, with one acting as a supplier and the other as a customer. An example of this synergy is the collaboration between Dragados and Iridium, where Dragados carries out the construction under concessions granted to Iridium. These interactions optimise operational efficiency and strengthen integration within the Group.

Own operations

This phase comprises all the activities and services carried out directly by the ACS Group. Detailed information on its business model and activities can be found in the section below on IRO-1. The main actors at this stage include:

• Own employees: These are employees hired directly by the ACS Group, who perform key duties for operations and the management of projects. Its work is essential to ensure efficiency, innovation and quality in provision of the Group's services, contributing to the achievement of its strategic and sustainability targets.
• Independent contractors: This category includes freelance professionals and temporary employees hired through temporary employment agencies. Their involvement brings flexibility to the Group's working structure, allowing it to adapt to the specific needs of each project. These professionals play a complementary role in the implementation of strategic activities, facilitating the optimisation of human resources.
• Executives: The ACS Group's executives are responsible for planning, managing and supervising the Company's activities. Their leadership directly impacts the Group's strategy, ensuring its operations are aligned with its business and sustainability targets. Through their decision-making, they drive the Group's efficiency, innovation and sustainable growth in the markets in which it operates.

Downstream

This phase includes all the stakeholders who are impacted by the ACS Group's activities and services, whether directly, indirectly, positively or negatively.

• Customers: Customers are the stakeholder group that purchases the ACS Group's services and activities directly. Their relationship with the company is key to the continuity and expansion of its business.
• End-users:These are the ultimate recipients of the services provided by the ACS Group or the beneficiaries of the infrastructures it builds. Their experience and satisfaction with projects or services influence the company's reputation and social impact.
• Local communities and indigenous peoples: Local communities and indigenous peoples are a stakeholder group for the ACS Group, given the impact of its activities in the territories where it operates. The Company remains actively committed to these communities, and their integration into the planning and implementation of its operations ensures the creation of shared value and the sustainable development of affected communities.
• ACS Group companies: As in the pre-operational phase, some Group companies enter into business relationships with each other once the infrastructure has been built. These synergies optimise

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management and ensure operational efficiency within the Group, making it more competitive and responsive to market demands.

The main inputs and outputs necessary for the Group to carry out its activities and services are:

• Inputs: employees, number of direct suppliers, number of significant suppliers, gross operational investments, energy consumption (MWh), water consumption (m3), wood (t), steel (t), concrete (t), cement (t), asphalt (t), among others.
• Outputs: revenues (in EUR million), net profit (in EUR million), portfolio (in EUR million), dividends paid and treasury stock, taxes paid, investment in social actions, Scope 1 emissions, Scope 2 emissions, Scope 3 emissions, and waste, among others.

Management of coal, gas and oil activities

As a global provider of infrastructure-related solutions and services, the ACS Group has, through the companies of its subsidiary CIMIC, a long history in the field of natural resource extraction. The Group's related companies in this sphere, Thiess and Sedgman, support the global process of decarbonising the economy. Thus, these companies are increasing their exposure to the mining of metals critical to the energy transition, thereby gradually reducing their relative exposure to coal mining activities.

Accordingly, the Thiess Group has committed to reduce its thermal coal revenues to 25% of its total revenues by 2027 and to less than 20% by the end of 2030, by intensifying its activity in metal mining. In 2024, Thiess recorded EUR 1.5 billion in sales in the coal mining sector. Metals such as lithium, copper and nickel are essential for renewable energy and electric vehicle technologies. In this way, the ACS Group is not only advancing the transition to clean energy, but also promoting the transition to more sustainable mobility.

The Risks identified with the mining sector are detailed in section SBM-3 of this chapter.

Sustainability strategy

ACS is a global leader in infrastructure development, key sectors for society, with the aim of building a better future. Its commitment to the social and economic progress of the countries in which it operates is realised through the development, financing and operation of engineering, civil works and construction projects, as well as new generation solutions in high added value sectors such as energy, digitalisation and smart mobility. Promoting sustainable development is one of the fundamental pillars of its corporate strategy, with the aim of generating shared value for all ACS stakeholders.

Thus, in the area of Sustainability, the ACS Group's strategy is based on a series of common targets developed in the 2025 Sustainability Master Plan approved by the Board in 2021 and in the targets set in the Group's Sustainability Policy. The various companies, under these common principles and with autonomy in their areas of competence, manage their resources as efficiently as possible to help meet these targets.

The 2025 Sustainability Master Plan sets out the Group's three strategic priorities and the twelve commitments with regard to sustainability that the ACS Group has set itself to continue Driving Overall Sustainability in Infrastructures:

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